Privacy Policy

Introduction.The purpose of this Privacy Policy is to describe how Coleman Research Group, Inc. (“Coleman” or “we” or “us”) collects, uses and shares information about you generally, including through Coleman’s online interfaces (e.g., websites and online portals) owned and controlled by us, including www.colemanrg.com (collectively referred to herein as the “Site”; all such data “Personal Data”).

We may modify this Privacy Policy and if any material changes are made to it, we will provide notice through our services or by other means to provide you the opportunity to review the changes before they become effective.

You acknowledge that your continued use of the Site after we publish or send a notice about our changes to this Privacy Policy means that the collection, use, and sharing of your Personal Data is subject to the updated Privacy Policy.

Data this Privacy Policy Covers.This Privacy Policy covers Personal Data, including through our Site. Some of our Site’s functionality can be used without revealing any Personal Data, though for some features, Personal Data is required. In order to access certain features on our Site, you may need to submit or we may collect, Personal Data.

Personal Data We Collect Relating to Your Use of Our Website. We may track, collect and aggregate information from your use of the Site, through the use of cookies or otherwise, indicating, among other things, which pages of our Site were visited, the order in which they were visited, when they were visited, and which hyperlinks were clicked. We also collect your IP address and standard log information, such as your browser type and operating system.

Personal Data We Collect Provided Directly by You or by Third Parties. We collect Personal Data that you provide to us when you register for an account, update or change information on your account, use our services, send e-mail messages, and / or participate in other services on our Site. During registration and later on our platform, we collect your name, e-mail, address, phone number and / or other information. We may also create Personal Data about you, such as records of your interactions with us, our clients, or our Experts, or from third parties that provide us with it or access to it.

How We Use Your Data.We may use your Personal Data for various purposes, subject to applicable law, including to:

Allow you to access and use the Site and to provide certain information, products, or services that you request from us.

Operate, manage, and communicate with you via our Site;

Notify you of changes to our Site or services.

Monitor, improve and develop our services to you.

Facilitate communications or transactions with you.

Share it with other parties as necessary in order for us to provide you with our services (e.g., cloud service providers, payment processors, etc.)

From time to time, we may use your e-mail address to send you information and keep you informed of products and services in which you might be interested. You may at any time elect to stop receiving such emails. Your contact information may also be used to reach you regarding issues concerning your use of the Site, including changes to this Privacy Policy.

How We May Share Personal Data.We may, for legitimate business purposes, disclose your Personal Data to other parties, including:

Your appointed representatives;

Other Coleman entities;

Professional advisors to Coleman, such as accountants, auditors and lawyers, and

Other parties as necessary in order for us to provide you with our services (e.g., cloud service providers, payment processors, etc.).

We may disclose your personal data to a third party if we believe in good faith that such disclosure is necessary or desirable (i) to comply with lawful requests, subpoenas, search warrants or orders by public authorities, including to meet national security or law enforcement requirements, (ii) to address a violation of the law, (iii) to protect the rights, property or safety of Coleman, its users or the public, or (iv) to allow Coleman to exercise its legal rights or respond to a legal claim.

If we engage a third party to process your Personal Data, that party will (i) only process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data, together with any additional requirements under applicable law.

Coleman is the data controller of your Personal Data.Coleman retains your Personal Data until either it is no longer necessary for the purpose for which it was collected, you withdraw consent to process your data or no other legal basis for processing exists.Coleman’s address is 575 Fifth Avenue, 21st Floor, New York, New York 10017, and you can contact Coleman via e-mail at compliance@colemanrg.com.

Legal basis for Processing: As explained above, we use your Personal Data in various ways, including depending on your use of the Site. We use your Personal Data on the following legal bases: (1) with your consent; (2) as necessary to perform our agreement to provide services; (3) where required by applicable law; (4) where necessary to protect the vital interests of any individuals; or (5) where we have a legitimate interest.

Transfers:Personal Data we collect may be transferred to, and stored and processed in, the United States or any other country in which we, our affiliates or third parties with whom we engage in order to provide our services maintain facilities. We will ensure that transfers of Personal Data to a third country or an international organization are subject to appropriate safeguard as described in Article 46 of the General Data Protection Regulation.

Right to Access and Correction. You can access your Personal Data and confirm that it remains correct and current by logging into the Site. You have the right to request access to your Personal Data and to receive a copy of your Personal Data, as well as certain information about our processing activities with respect to your Personal Data. You have the right to request correction or completion of your Personal Data if it is inaccurate or incomplete. You have the right to restrict our processing if you contest the accuracy of the data we hold about you, for as long as it takes to verify its accuracy.If you are a current Coleman client or a current member of our expert network and would like a copy of your Personal Data, please login to the Site and click on the ‘Personal Data’link at the bottom of the page and follow the instructions (if you are not a current Coleman client or a current member of Coleman’s expert network and would like a copy of your Personal Data, please send an e-mail to:compliance@colemanrg.com).

Right to Personal Data Portability.Where technically feasible, you can request that your personal Data be transmitted directly from Coleman to another data controller in a structured, commonly used and machine-readable format.If you would like to request your Personal Data to be ported, please log in to the Site and click on the ‘Personal Data’link at the bottom of the page and follow the instructions (if you are not a current Coleman client or a current member of Coleman’s expert network and would like a copy of your Personal Data, please send an e-mail to:compliance@colemanrg.com).

Right to Request Data Erasure.You have the right to have your data erased from our Site if the data is no longer necessary for the purpose for which it was collected, you withdraw consent and no other legal basis for processing exists, or you believe your fundamental rights to data privacy and protection outweigh our legitimate interest in continuing the processing.Your Personal Data will generally be erased from the Site without undue delay; we will retain your Personal Data in a de-personalized format in order to be able, if necessary, to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our Terms and Conditions or agreements, or fulfill your request to “unsubscribe” from further messages from us. If you would like to request the erasure of your Personal Data from our Site, please log in to the Site, and click on the ‘Personal Data’link at the bottom of the page and follow the instructions (if you are not a current Coleman client or a current member of Coleman’s expert network and would like a copy of your Personal Data, please send an e-mail to:compliance@colemanrg.com).

Right to Withdraw Consent. Where we process your Personal Data on the basis of your consent, you have the right to withdraw consent. If you would like to withdraw your consent to the processing of your Personal Data, please send an e-mail to:compliance@colemanrg.com.

Right to Lodge Complaint.You have the right to lodge a complaint with the appropriate relevant data protection supervisory authority in your EEA country of residence (e.g., the Information Commissioner’s Office in the United Kingdom).